NATIONAL ASSOCIATION OF STATE UTILITY CONSUMER ADVOCATES

R E S O L U T I O N

Supporting a Reduction in the Residential and Single Line
Business Subscriber Line Charges and Increased Federal Contribution
to the Lifeline Assistance Program in Response to the Recommended
Decision of the Universal Service Joint Board

WHEREAS, the federal-state Joint Board, of which the Missouri Public Counsel Martha Hogerty was a member, issued a Recommended Decision on November 8, 1996 at In the Matter of Federal-State Joint Board on Universal Service, CC Docket No. 96-45 which concerned the implementation of Section 254 of the Telecommunications Act of 1996;

WHEREAS, contained within Section 254 are Subsection 254(b)(2), requiring quality service to be provided at just, reasonable, and affordable rates; Subsection 254(b)(4) requiring telecommunications providers, rather than end users, to make equitable and nondiscriminatory contributions to the preservation and advancement of universal service; Subsection 254(i) requiring universal service to be provided at just, reasonable, and affordable rates; and 254(k) requiring that universal service should bear no more than a reasonable share of joint and common costs;

WHEREAS, various state consumer advocates, and other parties have filed comments in this proceeding advocating, inter alia, that the Subscriber Line Charge (SLC) should be reduced and that federal benefits to low income consumers should be increased;

WHEREAS, the residential SLC has not been reduced since it was increased to $3.50 in 1989, even though many other telecommunications rates set by the FCC have been reduced since that time;

WHEREAS, Carrier Common Line Charge (CCLC) reductions have occurred in the past and these reductions have facilitated reductions in toll rates, but no SLC rate reductions have occurred;

WHEREAS, all SLC revenue represents approximately 66% of revenue used to recover the interstate portion of common line cost with the remainder recovered from the CCLC, which is directly assessed to interexchange carriers;

WHEREAS, the FCC concluded in Amendment of Part 67 of the Commission’s Rules and Establishment of a Joint Board, 2 FCC Rcd 2953, 2958 n.36, (1987) that payment of 50% of common line costs by the Interexchange Carriers through the CCLC would represent a “fair share” of common line cost recovery;

WHEREAS, consumers should share in the productivity benefits realized by the telecommunications industry;

WHEREAS, NASUCA supports reducing, and expeditious elimination of, the SLC as the SLC functions as a component of local rates;

WHEREAS, many low income consumers continue to go without telephone service;

WHEREAS, many states have not implemented Lifeline programs or have implemented such programs at less than the maximum available federal benefit;

WHEREAS, the Joint Board on November 8, 1996 issued a Recommended Decision and such Recommended Decision will be reviewed and voted upon by the full Federal Communications Commission on May 8, 1997;

WHEREAS, the Recommended Decision conditionally proposes that the SLC for the initial Residential connection for the primary residence and for Single Line Business customers should be reduced by one half of the CCLC reduction produced by the transfer of the Long Term Support revenues from the CCLC to a High Cost Fund and, also, by the CCLC reduction produced by the removal of pay phone support from the CCLC;

WHEREAS, the Recommended Decision proposes that all Lifeline customers will receive $5.25 per month in federal assistance and that additional state assistance will be matched by federal assistance in a ratio of 2:1 up to a maximum $7.00 federal contribution;

WHEREAS, the Recommended Decision proposes that Lifeline assistance should expand to all states and territories; that all Lifeline eligible customers may not lose local service for nonpayment of toll charges; that toll blocking and toll limitation services should be available at no charge for Lifeline customers; and that there shall be no service deposits required for Lifeline customers who elect toll blocking service;

THEREFORE BE IT RESOLVED that NASUCA supports a reduction of the SLC as consumers should share in the productivity benefits enjoyed by the telecommunications industry by have not received any reduction in the SLC since it was set at $3.50; consumers;

THEREFORE BE IT FURTHER RESOLVED that NASUCA supports the recommendation of the Joint Board as set forth above concerning assistance to low income consumers;

THEREFORE BE IT FURTHER RESOLVED that NASUCA supports a SLC reduction in the amount recommended by the Joint Board as a minimal step in redressing the inequity involving the SLC as demonstrated above;

THEREFORE BE IT FURTHER RESOLVED that NASUCA authorizes its Executive Committee to develop specific positions and to take appropriate actions consistent with the terms of this resolution. The Executive Committee shall notify the membership of any action taken pursuant to this resolution.

Approved by NASUCA:

San Francisco, California
Place

November 19, 1996